Addressing Climate Change Without Legislation - Volume 2: FERC

Abstract

Perkins, supra note 37, at 993. See also American Clean Skies Foundation, Letter to FERC: Comments on Proposed Rule for Demand Response Compensation in Organized Wholesale Energy Markets, Docket No. RM17-10-000, 4, available at http://elibrary.ferc.gov/idmws/file_list.asp?document_id=13817172 (FERC, May 13, 2010) (arguing that fossil fuel generation is "typically mispriced because wholesale prices radically understate the full environmental and health costs associated therewith"); Environmental Defense Fund, Submission to FERC: Docket No. RM10-17-000, 2-3 (FERC, Oct. 13, 2010), available at http://elibrary.ferc.gov/idmws/file_list.asp?document_id=1385678 (stating that "current market prices fail to internalize environmental externalities-including…greenhouse gas ("GHG") pollution").